118 STAT. 1420 PUBLIC LAW 108–357—OCT. 22, 2004 Sec. 402. Recharacterization of overall domestic loss. Sec. 403. Look thru rules to apply to dividends from noncontrolled section 902 cor porations. Sec. 404. Reduction to 2 foreign tax credit baskets. Sec. 405. Attribution of stock ownership through partnerships to apply in deter mining section 902 and 960 credits. Sec. 406. Clarification of treatment of certain transfers of intangible property. Sec. 407. United States property not to include certain assets of controlled foreign corporation. Sec. 408. Translation of foreign taxes. Sec. 409. Repeal of withholding tax on dividends from certain foreign corporations. Sec. 410. Equal treatment of interest paid by foreign partnerships and foreign cor porations. Sec. 411. Treatment of certain dividends of regulated investment companies. Sec. 412. Look thru treatment for sales of partnership interests. Sec. 413. Repeal of foreign personal holding company rules and foreign investment company rules. Sec. 414. Determination of foreign personal holding company income with respect to transactions in commodities. Sec. 415. Modifications to treatment of aircraft leasing and shipping income. Sec. 416. Modification of exceptions under subpart F for active financing. Sec. 417. 10 year foreign tax credit carryover; 1 year foreign tax credit carryback. Sec. 418. Modification of the treatment of certain REIT distributions attributable to gain from sales or exchanges of United States real property interests. Sec. 419. Exclusion of income derived from certain wagers on horse races and dog races from gross income of nonresident alien individuals. Sec. 420. Limitation of withholding tax for Puerto Rico corporations. Sec. 421. Foreign tax credit under alternative minimum tax. Sec. 422. Incentives to reinvest foreign earnings in United States. Sec. 423. Delay in effective date of final regulations governing exclusion of income from international operation of ships or aircraft. Sec. 424. Study of earnings stripping provisions. TITLE V—DEDUCTION OF STATE AND LOCAL GENERAL SALES TAXES Sec. 501. Deduction of State and local general sales taxes in lieu of State and local income taxes. TITLE VI—FAIR AND EQUITABLE TOBACCO REFORM Sec. 601. Short title. Subtitle A—Termination of Federal Tobacco Quota and Price Support Programs Sec. 611. Termination of tobacco quota program and related provisions. Sec. 612. Termination of tobacco price support program and related provisions. Sec. 613. Conforming amendments. Sec. 614. Continuation of liability for 2004 and earlier crop years. Subtitle B—Transitional Payments to Tobacco Quota Holders and Producers of Tobacco Sec. 621. Definitions. Sec. 622. Contract payments to tobacco quota holders. Sec. 623. Contract payments for producers of quota tobacco. Sec. 624. Administration. Sec. 625. Use of assessments as source of funds for payments. Sec. 626. Tobacco Trust Fund. Sec. 627. Limitation on total expenditures. Subtitle C—Implementation and Transition Sec. 641. Treatment of tobacco loan pool stocks and outstanding loan costs. Sec. 642. Regulations. Sec. 643. Effective date. TITLE VII—MISCELLANEOUS PROVISIONS Sec. 701. Brownfields demonstration program for qualified green building and sus tainable design projects. Sec. 702. Exclusion of gain or loss on sale or exchange of certain brownfield sites from unrelated business taxable income. Sec. 703. Civil rights tax relief. Sec. 704. Modification of class life for certain track facilities. Sec. 705. Suspension of policyholders surplus account provisions. Sec. 706. Certain Alaska natural gas pipeline property treated as 7 year property.
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